Grantee Guidance: Allowable/Unallowable Costs
Allowable costs are costs that can be reimbursed by the grant. Generally, a cost is allowable if it is incurred through work activities that:
- Are necessary for producing the outcomes described in the grant agreement and associated scope of work
- Occur within the grant period
Allowable and unallowable costs vary by the type Safe Routes to School grant program and funding source; specifics are identified within grant program policies and/or guidance.
Generally speaking, non-infrastructure activities using state funds adhere to legislation that governs the SRTS program. (Minn. Stat. 174.40, subd. 7a) This legislation indicates funding should be used for planning activities, public awareness campaigns and outreach to press and community leaders, traffic education and enforcement in the vicinity of schools, student sessions on bicycle and pedestrian safety, health, and the environment, financial assistance for training, volunteers, and managers of safe routes to school programs.
Existing SRTS programs have used non-infrastructure funds for the following purposes:
- Creation and reproduction of promotional and educational materials.
- Engagement with priority populations to better understand barriers to walking and bicycling Classes or assemblies that teach students and/or parents safety practices relating the Walk! Bike! Fun! Curriculum created in partnership with the Minnesota Department of Education.
- Development and implementation of curricula that support students issues with personal safety, street harassment, and bullying in communities where these issues prevent walking and bicycling.
- Training, including SRTS training workshops that target school- and community-level audiences.
- Modest incentives for SRTS contests, and incentives that encourage more walking and bicycling over time.
- Classes or assemblies that teach students and/or parents safety practices relating to bicycling and pedestrian behavior, such as the proper way to cross streets, use sidewalks, avoid darting out from between parked cars, helmet use, bicycle skills, etc. Messaging is reinforced through e-newsletters, handouts, posting in school bulletin, etc. Minnesota has a Walk! Bike! Fun! Curriculum created in partnership with the Minnesota Department of Education that has several resources for a variety of education events.
- Bicycles and trailers/storage that allow school(s) to offer the skills training for students to become competent riders. Reference the Bike Fleet Guide for additional guidance
- Bike racks that are APBP compliant and create safe space for students to secure bicycles that are in highly visible and accessible from the school entrance.
- Safe Routes to School maps of suggested walking and bicycling routes to and from school using resources like the MnSRTS Mapping resources.
- Public Awareness Campaigns that encourages bicycling and walking for transportation. This can include any number of tools such as flyers, print and media advertising, social media campaigns, poster contests, special events, etc.
- Signage that would be on private property of a school facility to aid in arrival/dismissal like no idling, no cell phone, bus only, etc signage. Signage cannot mimic roadway authority signage. Signage may include sandwich boards, banners, yard signs, etc.
- Walking School Bus or Bike Train with adults who accompany children to school, stopping at designated locations where children can join the “bus” or “train” at pre-arranged times.
- Encouragement Programs such as “Walking and Wheeling Wednesdays” or “Tires ‘n Tennies Tuesdays” (TnT Tuesdays) that promote weekly, or even daily, active school transportation. Prizes or incentives to help children sustain the activity throughout the school year can be provided at the individual level, classroom level, or among schools.
- Safety and educational tokens that also advertise the program.
- Equipment and supplies for implementing the SRTS program
- Photocopying, duplicating, and printing costs, including CDs, DVDs, etc.
- Mailing costs
- Costs for data gathering, analysis, and evaluation reporting at the local project level
- Pay for substitute teacher if needed to cover for faculty attending SRTS functions during school hours
- Equipment and training needed for establishing crossing guard programs
- Stipends for parent or staff coordinators. This is an important possibility to keep open for low-income communities. It may be beneficial to set a limit on the maximum value of a stipend, such as $2000/school year.)
- Costs to employ a SRTS Program Manager, which is a person that runs a SRTS program for an entire city, county, or some other area-wide division that includes numerous schools.
- Costs to engage the services of a consultant (either non-profit or for-profit) to manage a SRTS program as described in the prior bullet.
This listing is not exclusive, although communities considering funding items not listed must ensure that the activity meets the purposes of the SRTS Program as specified by legislation, that the item is generally comparable to those listed above or in the legislation, and verify with the SRTS project manager.
For projects using federal funding, the federal regulations under 2 CFR 200 provide additional guidance beyond the state funded projects as to the eligible use of funds.
The following is a list of unallowable uses of MnDOT SRTS funds. Please note this is not an exhaustive list. MnDOT staff will review all invoices and reserve the right to question and/or take action for inappropriate uses of funds.
- Alcohol or any illegal substance
- Any cost not directly related to the SRTS grant
- Bad debts
- Capital improvements
- Cash assistance paid directly to individuals to meet their personal or family needs
- Contributions or donations
- Costs incurred prior to the grant award or after the grant termination
- Direct patient medical services
- Fines and penalties
- Gift Cards
- Gifts for staff
- Goods or services for personal use
- Lobbying at the federal, state or local level
- Losses on agreements or contracts
- Memberships to clubs, camps, fitness centers and similar groups
- Mischarging of costs
- Political campaigns on behalf of, or in opposition to, any candidate for public office
- Raffles (raising money by selling tickets)
- Research (The distinction between research and program evaluation is complex and dependent on the purpose of the study. However, the difference can be summarized in this way: “Research… is done for the purposes of generating knowledge, whereas program evaluation is done for the purpose of understanding the extent to which the intervention was effective” (Issel, 2009).
- Scholarships (includes camp fees and scholarships for individuals to participate in events, classes or programs not linked to SRTS)
- Staff meals (except during approved travel)
- Supplanting of funds from other sources
Determining if Expenditures are Allowable/Unallowable
With the exception of the expenses noted as unallowable, grantees can determine whether or not an expense is allowable using MnDOT SRTS funding using this decision-making process. Grantees should use the following questions:
- Does the request fall within the FHWA guidelines for SAFETEA-LU funds?
- Is the expense specifically identified in your SRTS grant contract?
- Who is the targeted population that will benefit from this item/expense, and does this expense reach a significant proportion of the targeted populations?
- Is the item or request reasonable, cost efficient and necessary?
- Is it a good use of public funds?
- Imagine a story about one of your MnDOT SRTS strategies was featured on the cover of your local newspaper. In the story, the reporter describes the strategy and items/expenses that have been incurred to support this strategy. Would this story be perceived by the public, potential critics, community leaders, decision makers and stakeholders, in a positive manner?
If the answer is YES to all of the above questions, then grantees may proceed with the expenditure. If the answer is no or unclear to one or more questions above, the grantee should send an email to their SRTS project manager for approval.